This document on
the treatment and disposal of petroleum contaminated soil (PCS), has
been developed to assist environmental consultants, petroleum service
contractors, waste disposal ground operators, and petroleum storage
tank owners in the management of petroleum contaminated soil. Leaking
petroleum storage tanks and petroleum contaminated sites can have
serious environmental and public safety implications. Contaminated
soil removed from petroleum storage tank sites requires proper
treatment and/or disposal to ensure it does not pose a safety, public
health, or environmental threat.

The following
sections of this document discuss procedures that may be used to meet
these objectives. Many people play a role in the management of
petroleum contaminated soils, and by reading this document you will
have a better understanding of how to properly dispose of and/or treat
petroleum contaminated soil.

1.1 Scope

The scope of this
document refers to soil contaminated with residual concentrations of
refined petroleum products such as gasoline, diesel fuel, aviation
fuel, fuel oil, waste oil, and related petroleum products stored in
petroleum storage tanks. This document does not supersede existing
regulations or policies governing the classification, handling,
disposal or treatment of petroleum contaminated soils and is intended
to serve as an aid to parties involved in the design and operation of
soil treatment facilities.

This document
outlines the requirements and operating procedures for the
disposal/treatment of PCS at licensed soil treatment facilities,
Manitoba Waste Disposal Grounds (WDG), and at single-use soil
treatment sites approved by Manitoba Environment.

The principle
treatment method for PCS at these types of sites is by landfarming.
Under normal circumstances, the operating philosophy of the soil
treatment facility should, to the maximum extent possible, control
excessive emission of volatile organic compounds (VOC) to the
atmosphere. In addition, losses of petroleum compounds by leaching,
should be controlled.

Manitoba
Environment has developed objective guidelines with recommended
clean-up criteria for the remediation of sites contaminated with
petroleum hydrocarbon compounds. Manitoba's remediation guidelines
recommend that the nature and extent of subsurface contamination be
delineated prior to the implementation of remedial activities. This
information will assist in determining the type(s) and range of
concentrations of petroleum hydrocarbon compounds in the contaminated
soil, and the amount of contaminated soil requiring treatment or
disposal.

Other existing
Manitoba Environment Guidelines pertinent to PCS are as follows:

• Guideline for
Environmental Site Investigations (Draft) April 1998.

• Guideline
for the Designation of Contaminated Sites in Manitoba (March
1997).

Copies of these and
other documents can be obtained by contacting Manitoba Environment.

3.0
CLASSIFICATION AND HANDLING OF PCS

It is important
that petroleum storage tank owners, or contractors working for the
tank owner, develop a handling plan prior to disposal of PCS. This
management plan should cover the handling of the PCS from cradle to
grave, and include procedures necessary for compliance with all
provincial regulations and local policies. (see Information
Bulletin 96-02E)

3.1
Classification

Prior to
developing a procedure for handling PCS to be removed from a site, it
is necessary to classify the soil based on the specific petroleum
product type in question, and the degree of severity of hydrocarbon
contamination. The subsequent handling, treatment and/or disposal of
contaminated soil are dependent on the classification. Classification
is based on results of analytical laboratory testing for petroleum
hydrocarbon compounds and should be conducted prior to excavation of
the soil.

Petroleum
contaminant concentrations should be determined in reference to the
Canadian Council of Ministers of the Environment Recommended Candadian
Soil Quality Guidelines.

3.2
Characterization of the Soil Shipment;

Detailed
characterization of PCS, specifically contaminant types and
concentrations, soil types and estimated volumes, must be conducted
prior to any soil being shipped to a soil treatment/disposal facility.
Procedures for characterization of the soil should follow those
outlined in the Manitoba Environment Guideline.

4.0 TRANSPORTATION
OF PCS

PCS is not
considered hazardous waste unless the soil is contaminated with
Polychlorinated Biphenyls or meets the primary classification for
classes 2 to 6 and 8 under The Dangerous Goods Handling and
Transportation Act and regulation thereunder. PCS generators who wish
to transport hazarous waste class PCS must ensure that they are
registered with Manitoba Environment and that the shipments are
manifested and transported by a licensed carrier pursuant to MR
175/85.

Trucks containing
the PCS should be equipped with tarpaulins to reduce wind blown
particles and volatilization of petroleum constituents. During PCS
transport, trucks must also effectively contain all residual liquids
generated from the soil.

5.0 PERMITTING
AND LICENSING PROCEDURES

The procedure for
obtaining authorization to establish and operate a facility for the
treatment of contaminated soils will depend on the type of facility
being proposed. The various approval processes are described in this
section. Regardless of the type of facility, it is anticipated that
the design and operating parameters will generally follow the
provisions in this guideline.

5.1
Municipal Waste Disposal Grounds

Soils which
contain petroleum contamination at a concentration below Manitoba
Level III criteria can be received at a landfill and used directly as
cover material without requiring further treatment. The landfill must
be in compliance with Manitoba Regulation 150/91 under the Manitoba
Environment Act. Written authorization from the appropriate regional
office of Manitoba Environment and the landfill owner must be obtained
for each originating site before this disposal option is used.

Where a designated
soil treatment facility is to be developed as part of a waste disposal
ground site, the authorization for the PCS facility will be issued as
a variance to the operating permit for the waste disposal ground
issued pursuant to Manitoba Regulation 150/91. The application for the
variance must contain adequate details to show that the proposed
facility will meet the standards of this guideline. The application
would be submitted to the appropriate Regional Director of the
Operations Division of Manitoba Environment. The variance, if
approved, would normally only apply to non-hazardous waste level
soils. Acceptance of hazardous waste level soils would be considered
on a site specific basis.

5.2
Commercial PCS Facilities

Proposals for soil
treatment facilities which are not located at a municipal waste
disposal ground, and which will be receiving soil from more than one
originating site, will be processed through Manitoba Environment's
regular licensing system. Facilities which will not be receiving
hazardous waste level soil will be considered for licensing under The
Environment Act. Facilities which intend to receive hazardous waste
level soils will require a licence issued under The Dangerous Goods
Handling & Transportation Act.

In either case,
the application must be submitted to Larry Strachan, Director of
Environmental Approvals at the Winnipeg office address shown on page
12.

5.3
Single Use Sites

Where existing
commercial facilities are not available in the vicinity of a
remediation project, consideration will be given to authorizing the
establishment of a single use site. If approved, the site would only
be used once for soils originating from one location. Single use sites
must be decommissioned once treatment of the soil is completed to a
satisfactory level.

Requests for
authority to establish a single use treatment site shall be submitted
to the appropriate Regional Director for Environmental Operations.
Operation of the single use site shall not commence until written
authorization has been received from the Director. No PCS classified
as hazardous waste shall be received at a single use treatment site.

5.4
Minimum Application Information

Prior to
developing a facility within the scope of this guideline, the
proponent must provide Manitoba Environment with enough information to
allow the department to assess whether the facility should be
permitted. Larger, more complex facilities, will require a greater
degree of detail in the proposal. As a general guide for all levels of
facilities*, the following minimum information should be included in
all applications:

• Name and
address for the owner and operator of the proposed facility.

• Name and
address of the owner of the land where the facility will be sited.

• Site
description to confirm that the site selection criteria outlined
in Sec. 6.2 have

been met.

• Physical
description of the proposed facility addressing the items
described in Sec. 6.2.

• Results of
any baseline studies done to confirm the acceptability of the
site.

•
Description of the acceptance criteria to be used for receiving
soil shipments.

•
Description of monitoring, sampling and record-keeping procedures.

• Proposed
uses for treated soil.

• Procedure
to be used to decommission the site when the operation concludes.

The application must
be accompanied by relevant maps, drawings and lab results.

* NOTE: The
Regional Director may waive the requirement to submit portions of the
information listed above for submissions for single use sites.

6.0
DESIGN AND OPERATIONS AT PCS TREATMENT/DISPOSAL SITES

The information
provided in this section describes, in a general sense, the typical
minimum requirements for the design and operation of PCS treatment
sites. More detailed information based upon the site specific
conditions at a potential PCS treatment sites can also be provided in
technical proposals which form part of approval submissions (see
Section 5.0).

6.1
Baseline Information and Inspections

Geological
and Hydrogeological Baseline Information

Prior to operation
of a treatment/disposal facility, subsurface baseline information
should be obtained on geological and groundwater conditions, to serve
as the basis for future comparisons.

If soil treatment
facilities are within the limits of Class I and Class II Manitoba
WDG's, data from the existing test holes and groundwater monitoring
systems may be used to establish baseline geological and groundwater
conditions. The design of a groundwater monitoring system and
monitoring requirements should be consistent with, and should include
appropriate analytical testing parameters for PCS.

Where appropriate,
soil textural analyses (i.e. grain size distribution, soil
classification) and in-situ, or laboratory soil permeability testing
should be conducted. Soil sampling for such analyses should be
conducted at representative depth intervals.

Soil and
Groundwater Chemistry Baseline InformationBaseline soil
information should also be obtained to establish chemical
characteristics of soils beneath the proposed treatment/disposal area.
Individual soil samples should be obtained at representative depth
intervals, and groundwater samples recovered from all water-bearing
zones. Each sample to be submitted for laboratory analyses should be
tested for the following parameters:• Soil Vapour
Concentrations.

• Total
Semi-Volatile and Total Volatile Hydrocarbons.

• Benzene,
Toluene, Ethylbenzene, Xylenes.

• Metals
(where appropriate).

• Other
Parameters (where appropriate).

Subsurface
Inspections and Monitoring

Routine
inspections should be conducted to confirm that operation of the
treatment facility has not adversely affected local groundwater
quality. Such inspections should, as a minimum, be conducted on an
annual basis. Groundwater monitoring parameters should follow the
baseline parameters outlined in the previous subsection.

6.2
Design Considerations

Site
Selection Criteria

The following
criteria must be taken into account when considering a candidate site
for a PCS treatment/disposal facility. Any variations from these
criteria must first be approved by Manitoba Environment:• A site cannot
be located in a groundwater pollution hazard area unless an
impermeable base is being prepared or a synthetic liner is
implemented.

• A 500 m
separation distance must be maintained from residences,
institutional or commercial buildings on other properties, or from
any body of surface water.

• The
proposed site location must be adequately separated from
neighbouring occupancies to minimize the potential for
objectionable odours beyond the property boundaries.

• The site
must be in an area with the appropriate zoning for the intended
land use.

Identification
and Lay-Out

An area used for
treatment of PCS should be identified as a "designated area"
which is used exclusively for this purpose. Such areas/facilities
should be clearly marked to prevent unauthorized access onto the
treatment area and possible disturbance or compaction. Physical
barriers are also recommended to restrict unauthorized access.

Permanent visible
markers (posts, pegs, etc.) should be installed at regular intervals
of 5 m to 10 m along 2 perpendicular edges of the treatment area to
serve as a reference grid for routine inspections and monitoring.

Location

Treatment cells
should be located in areas where the underlying native soils consist
of relatively low permeability deposits. Where this is not practical,
the subgrade soil should be suitably prepared in order to provide a
low permeability barrier to minimize vertical migration of leached
petroleum contaminant compounds.

Siting of
treatment cells in local depressions or on sloping ground with
gradients of 5% or greater should be avoided.

Treatment cells
should normally be located in areas where the local groundwater table
is at least 3.0 m below the prepared base so as to minimize the
possibility of groundwater contamination, to avoid saturation of the
treatment layer due to groundwater fluctuations or capillary action,
and to minimize susceptibility of the prepared base to frost action.

Soils impacted
with petroleum hydrocarbons with benzene, toluene, ethylbenzene and
xylene (BETX), where any of these individual constituents exceed 100
ppm (high impacted soils), shall be managed separately from other
contaminated soils in a dedicated cell for treatment at Municipal
Waste Disposal Grounds and Commercial PCS Facilities. The location of
this cell shall be provided to the appropriate Manitoba Environment
regional office.

Site
Preparation

Treatment cells
should be surrounded by berms to prevent surface water runoff and
run-on. The berms should be designed to permit equipment access and
have a minimum height of 0.5 m. Temporary cross-berms or windrows may
also be provided to avoid mixing and cross-contamination of different
soil shipments.

The base of
treatment cells should be lined to prevent downward migration of
contaminants below the treatment layer. The liner may consist of
synthetic material, compacted clay, or a combination of both.
Synthetic liners should be resistant to deterioration by sunlight and
by petroleum hydrocarbon compounds, and should be installed to avoid
puncture or tearing from soil spreading and tilling operations. Unless
determined otherwise based on site-specific conditions, clay liners
should normally have a minimum compacted thicknesses of 500 mm.

The base of the
treatment area should be graded to facilitate surface drainage. A
gradient of 1% to 2% will normally be adequate for this purpose. The
impermeable layer on the base of the cell should be covered with a
sacrificial indicator layer of sand, gravel or straw to ensure that
the base is not penetrated during tilling or soil removal operations.

Design of
treatment cells should include provisions to contain internal storm
runoff and seepage in order to prevent offsite losses, and inundation
of the treatment layer. Sumps or internal drainage ditches installed
for this purpose should be suitably lined. Internal and external
surface drainage systems must be capable of accommodating runoff
volumes resulting from a 24-hour, 10 year frequency storm.

Monitoring
Wells

The installation
of monitoring wells must be incorporated in the design of the
treatment area. In general, monitoring wells should be designed in
order to monitor any groundwater contamination within the regional
aquifer and within any perched groundwater-bearing soil formations
beneath the site. The total number, location, and completion design of
the monitoring wells must be approved by Manitoba Environment, prior
to installation.

6.3
Operating ConsiderationsInventory
Control

Operation of soil
treatment facilities should incorporate inventory control and
management procedures that account for the status and progress of the
various individual soil shipments being treated concurrently.
Information for contaminated soil for each originating site should
include, but not necessarily be limited to, the following:

• Origin of
the contaminated soil.

• Number
of soil shipments.

• Total
volume of PCS.

•
Contaminant type(s) and concentrations.

•
Placement area.

•
Destination for remediated soil.

Where high impacted
soils are received (BTEX exceeding 100 ppm for any of these
constituents), the following information shall also be provided to the
appropriate Manitoba Environment regional office within 5 working
days:• Results of
analytical testing by an accredited laboratory (Information

PCS placed in the
treatment area should be spread in an even layer in a manner that
avoids compaction and inter-mixing of different soil shipments.

The final
thickness of the treatment layer normally should not exceed 300 mm or
the effective mixing depth of on-site equipment (discs, roto-tillers,
etc.), whichever is less.

Boulders and other
large debris should be removed from the treatment layer to avoid
potential damage to the tilling/aeration equipment, and to provide for
optimum soil tillage.

Alternatively,
soil may be placed in windrows which should normally not exceed 1 m in
height. The windrows will require periodic mixing in a similar fashion
to a treatment layer as described in the following section.

Layer
Amendments

The treatment
layer should be thoroughly aerated (mixed/tilled) on a regular basis.
In most cases, a tillage frequency of 1 to 2 weeks should provide
optimum soil aeration while minimizing excessive VOC emissions. In
cases where enhanced soil remediation operations are being conducted,
soil tilling frequency can be modified to suit the requirements of the
remediation methods employed.

Soil augmentation
procedures such as addition of fertilizers, desiccants, and soil
bulking agents, are to be conducted only as approved within the
licence or permit for the facility.

Periodic
irrigation of the treatment layer may be necessary to avoid
desiccation or prevent excessive wind blown dust. However, saturation
of the soil should be avoided. Water impounded in runoff/leachate
sumps may and should be used for treatment layer irrigation.

The use of sewage
effluent or sewage sludge as an amendment is not recommended as it can
introduce other contaminants into the soil.

Control/Discharge
of Impounded Water

The soil treatment
site must be capable of preventing run-on and run-off water from
contacting contaminated soil. In addition, run-off water from the PCS
treatment facility must be controlled on-site in order to prevent
migration of contaminants. Surface water control will generally
involve use of ditches, sumps, and culverts, along with a properly
graded land surface.

Prior to any
discharge or removal of impounded surface water from the PCS treatment
facility, representative analytical testing of the water for petroleum
hydrocarbon compounds must be conducted and the results reviewed by
Manitoba Environment.

Air
Monitoring

Where high
impacted soils are being managed, air monitoring shall be conducted to
ensure the following concentration limits are not exceeded at the
property boundaries:

Air
Contaminant

Period
of Time Air

Contaminant
is Measured

Concentration
Limit

Total
Hydrocarbons

24-hour
average

32 mg/m3

Benzene

24-hour
average

150 µg/m3

Toluene

24-hour
average

2000 µg/m3

Ethylbenzene

24-hour
average

4000 µg/m3

Xylenes

24-hour
average

2300 µg/m3

Air sampling shall be
undertaken in adherence to accepted protocols and conducted during the
period from April to November. The 24-hour average should commence
during periods where volatilization will be at the maximum (i.e. soil
placement and tilling). Air monitoring reports shall be provided to
Manitoba Environment within 30 days of the sampling event.

6.4
Confirmatory Testing of Treated Soil at PCS Treatment Site

Confirmatory
laboratory testing should be conducted on representative samples from
the treatment layer in order to demonstrate that the accepted clean-up
criteria have been achieved prior to re-use of the soil, as defined in
Section 7.0 of this document.

Testing
Protocol

The timing and
methodology for confirmatory soil testing may be based on preliminary
field hydrocarbon vapour testing of soil samples.

Soil vapour
concentration measurements can be used as an indicator of the relative
level of volatile hydrocarbons remaining in the soil. Using this
technique field screening technique, the more highly contaminated
areas of the treatment layer ("hot spots") can be
identified. Once soil vapour concentrations have been lowered to near
background levels in these areas, soil samples may be obtained for
confirmatory laboratory analyses to prove that the appropriate
clean-up criteria have been achieved.

Soil vapour
concentrations within the treatment layer should be carried out
according to Appendix A of the Manitoba Environment Guideline. Such
measurements should be conducted on a regular grid pattern. A grid
spacing of 5 m will ensure detection of "hot spots"
equivalent to 10 m3 (one truck-load spread 300 mm thick) with an 80%
confidence level.

Soil vapour
surveys should not be conducted under saturated soil conditions.

NOTE:
The use of soil vapour surveys as the basis for confirmatory
soil testing may not be appropriate for some less volatile
petroleum products such as diesel fuel and lube oils. In such
cases, soil sampling and laboratory analyses would be required.Confirmatory
Soil Sampling

Confirmatory
laboratory analyses are to be conducted at the end of the remediation
period to determine if acceptance criteria have been achieved.

Individual soil
samples are usually combined to form one or more "composite"
sample for the purpose of laboratory analyses. As a guideline, soil
sampling should be conducted for every 20 m3 of PCS in order to
generate a single composite sample for confirmatory laboratory
analyses. For example, for a total volume of 100 m3 of treated PCS, a
single composite sample should contain soil obtained from five
locations within the contaminated soil mass.

The recommended
number of composite soil samples to be submitted for confirmatory
laboratory analyses is dependent upon the volume of the treatment
layer as follows:

Soil
Volume (m3)

Number
of Composite Soil Samples
for Laboratory Testing

<100

1

100 - 500

3

500 - 1000

5

1000 - 2000

6

>2000

Representative
Number

The above approach is
biased towards the most contaminated portions of the treatment layer
and, therefore, results may be conservative.

Depending on the
variability of contaminant concentrations and soil conditions in the
treatment layer, more or less analyses may be required.

Where field
vapour screening methods have been used and are applicable,
confirmatory laboratory analyses may be concentrated in the areas of
pre-defined "hot spots" having the most elevated vapour
concentrations.

Sample
Collection Procedures

Sample collection
should be conducted by [personnel who have been adequately trained in
proper sampling procedures. Only pre-cleaned dedicated sampling
equipment and containers should be used. Care must be taken to limit
potential cross-contamination.

All sampling
procedures should conform to accepted methods and protocols.

6.5
Record Keeping and Reporting

The PCS treatment
facility operator/owner must maintain a current inventory of the
volumes of soil and contaminant types and concentrations within the
soil being treated as indicated in Section 6.3. As required under
section 6.3, the information for the treatment and disposal of high
impacted soils shall be provided to the appropriate Manitoba
Environment regional office within 5 working days. Submission of
year-end reports to Manitoba Environment will be required. In
addition, this information should be readily available and produced at
facility inspections conducted by Manitoba Environment during the
operation season.

7.0
REMOVAL AND RE-USE OF TREATED SOIL

The main objective
of remediation of PCS is to reduce hydrocarbon concentrations to
acceptable levels such that the soils are suitable for appropriate
re-use.

PCS which has been
treated to Manitoba Level III criteria for soil, as identified below,
can be used directly as landfill cover material in a waste disposal
ground upon approval by the WDG authority and the local regional
office of Manitoba Environment. Treated PCS which contains greater
than Level III concentrations of petroleum hydrocarbon compounds,
cannot be used as cover soil directly, but would require additional
active treatment within the WDG area as approved.

Unless otherwise
approved by Manitoba Environment, treated soil cannot be deposited on
a site which does not contain pre-existing contamination at
concentrations greater than or equal to the residual contaminant
levels in the treated soil.

8.0
DECOMMISSIONING OF PCS TREATMENT FACILITY

Submissions for
operation of a PCS treatment site must include a site decommissioning
plan which describes the steps to be undertaken in restoration of the
site following the completion of soil treatment operations. The plan
should include investigation of subsurface conditions beneath the
active soil treatment layer area. Investigations should follow the
procedures outlined in the Manitoba Environment Guideline. In
addition, the plan should describe procedures for the removal of any
infrastructure (i.e. buildings, berms, sealing monitoring wells), and
regrading of the land surface to original grade.

Submission and
approval of a site decommissioning report to Manitoba Environment will
be required.